Description: In United States v. Farris, court-appointed attorney Steven N. Howe admitted using Westlaw CoCounsel to draft appellate briefs that reportedly included AI-generated false quotations and misleading descriptions of precedent. The filing disrupted Farris's appeal, leading the court to appoint new counsel and restart briefing, while Howe lost his compensation and faced possible disciplinary action.
Editor Notes: Timeline notes: The incident ID date is 10/21/2025, based on the docketed filing date of Steven N. Howe's principal appellate brief (see filing 16 here: https://dockets.justia.com/docket/circuit-courts/ca6/25-5623), which the Sixth Circuit later found contained AI-generated false quotations and misleading descriptions of legal authorities. A Sixth Circuit opinion issued on 04/03/2026 documented Howe's use of Westlaw CoCounsel and the resulting procedural and professional consequences (see that here: https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0105p-06.pdf). The incident ID was created on 07/06/2026.
Entities
View all entitiesAlleged: Thomson Reuters , Large language model developers and AI research tool developers developed an AI system deployed by Steven N. Howe , Legal professionals and Law firms, which harmed United States Court of Appeals for the Sixth Circuit , Legal clients , Judicial integrity , John C. Farris and Epistemic integrity.
Alleged implicated AI systems: Westlaw CoCounsel , AI-assisted legal research systems and Large language models
Incident Stats
Incident ID
1572
Report Count
1
Incident Date
2025-10-21
Editors
Daniel Atherton
Incident Reports
Reports Timeline
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From Friday's Sixth Circuit decision in U.S. v. Farris, by Judges Eric Clay, Julia Gibbons, and Whitney Hermandorfer:
Howe [a court-appointed criminal defense lawyer appealing a drug trafficking sentence] filed two briefs---a principal bri…
Variants
A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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